- 2 - Additions to Tax Sec. Sec. Sec. Year Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6661 1986 $590,852 $29,543 * $147,713 1987 254,088 12,704 * 63,522 1988 280,624 14,031** -- 70,156 * 50 percent of interest due on portion of underpayment attributable to negligence. ** For 1988, the applicable addition to tax was determined under sec. 6653(a)(1). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. After concessions, the issues for decision are whether Ambrosio G. Makalintal, petitioner’s former husband, and petitioner underreported their income, and, if so, whether petitioner qualifies as an innocent spouse under section 6013(e). FINDINGS OF FACT Some of the facts have been stipulated and are so found. In 1967, Mr. Makalintal and petitioner were married in the Philippines, and until 1985 (when they moved to the United States), Mr. Makalintal and petitioner were residents and citizens of the Philippines. Prior to their divorce in 1990, Mr. Makalintal and petitioner had three children.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011